LAST UPDATED: DECEMBER 07, 2020

Qwest Investment Management Corp. and its corporate affiliates (“QWEST”, “we”, “us”, “our”) understands that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Statement. You can obtain more information about how we collect, use, disclose and protect your personal information by reviewing our full Privacy Statement below.

What personal information do we collect?

  • We collect personal information directly from users of our website, www.qwestfunds.com (the “Website”) or services, including name, date of birth, address, phone number, email, emergency address, gender and name(s) of partners and children. Users may also provide additional information by choosing to fill out free-form fields on our Website.
  • By using our Website, software, or services, you are choosing to provide us with your personal information and you acknowledge and consent to the processing of your personal information in Canada.
  • We also collect personal information directly from you if your reach out to us directly by telephone or email.
  • We also use cookies on our Website and automatically collect certain information about the way our Website is used.
  • Our Website also collects users’ location information.

Why do we collect personal information and how is it used?

  • We collect personal information to facilitate the use of our Website and services.
  • We also use personal information for research purposes.
  • The personal information that we collect about devices and use of our Website is used in aggregate and de-identified form to evaluate and improve our services.

Is personal information shared or disclosed?

  • Personal information provided to us is never sold or rented to other organizations.
  • We also use certain third party service providers who may have access to the information we collect.
  • We may also disclose or share personal information for fraud prevention, and other permitted disclosures under applicable law.

What are the risks?

  • Although we take steps to safeguard the personal information under our control, "perfect security" does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Website or via email. It is possible that third parties may unlawfully intercept or access such information.

What are your choices?

  • You may request access to and review of your personal information in our possession, subject to certain limitations.
  • You may also request that we change or delete your personal information in our possession. We will make best efforts to comply with such requests, subject to certain limitations.

What else should you know?

  • We may amend our Privacy Statement from time-to-time. Although we will notify you of major changes, we encourage you to check for updates.
  • You can contact us with questions, complaints or to access your personal information.

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.  By using our Website or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in Canada in accordance with this Privacy Statement and as may be further identified when the personal information is collected. If you are located or residing outside of Canada, please be aware that our Website and Service are intended for and directed to users in Canada, and the privacy laws and principles in Canada may differ and not offer the same level of protection as those in your location or residing country/region. Through your continued use of our Website or Service, you are transferring your personal information to Canada and you expressly consent to that transfer. We will use this consent as the legal basis for such data transfer, unless otherwise stated in this Privacy Statement.

If you do not consent to the processing of your personal information in accordance with this Privacy Statement, please do not access or continue to use any of the Website or Service or otherwise provide any personal information to us.

Privacy Statement

Qwest Investment Management Corp. and its corporate affiliates (“QWEST”, “we”, “us”, “our”)) values the trust and confidence you place in us. Respecting your privacy and protecting your personal information are an integral part of our commitment to service excellence. The QWEST Privacy Statement (“Privacy Statement”) outlines the principles and commitments we make to protect your privacy and personal information.

This Privacy Statement applies to the collection, use or sharing of any personal information collected by QWEST in the course of conducting our business. It will continue to apply for as long as QWEST holds your information, including after the termination of any of your product or service agreements with us. By providing QWEST with information, you are consenting to the collection, use or sharing of your information as set out in this Privacy Statement.

For the purposes of this policy, “personal information” or “information” is defined as information about an identifiable individual such as contact information, account numbers or details, such as age, marital status and financial information. This information can be in any form including paper, electronic, audio, video or biometric, such as voiceprints, photographs and signatures.

1. Your Consent

QWEST requires your consent to collect, use, disclose, or retain your personal information. Consent can be express, implied, or given through an authorized representative such as a lawyer, agent, or broker. Express consent may be given orally, in writing, or electronically. Implied consent is obtained when QWEST can reasonably infer consent based on your circumstances. Subject to legal, business or contractual requirements, you can withdraw or refuse your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, this withdrawal or refusal may impact the products or level of service that we provide you. If this information is required by law, QWEST may decline or discontinue membership.

There are a limited number of situations where we may disclose your personal information without your consent including:

  1. when it is permitted or required by law;
  2. when there is reason to suspect that a client may be the victim of abuse and QWEST is disclosing the information to a government institution or an authorized representative;
  3. to deal with an anticipated breach of law;
  4. to collect a debt from you; or
  5. during an emergency that threatens a person’s life, health or personal security.

If you do not consent to the processing of your personal information in accordance with this Privacy Statement, please do not access or continue to use any of the Website, Software or Service or otherwise provide any personal information to us.

2. Your Personal Information

QWEST collects personal information about you, directly or indirectly, from:

  1. our interactions with you;
  2. products and services you have with QWEST;
  3. cookies and other tracking information through your use of our Website;
  4. credit bureaus and other financial institutions;
  5. government institutions and regulatory authorities;
  6. third parties or public sources (e.g. land registers, news, and Internet sites, including social media sites); and
  7. any references you have provided.

We only collect personal information that we need. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us. Your personal information will be collected, used, disclosed, and retained for the purpose for which it was obtained or for purposes authorized or required by law. QWEST will not collect, use, disclose, or retain personal information for any other purposes unless your consent to do so is obtained.

We collect information about you to verify your identity, to help us serve you as our client, to understand and meet your financial needs, to access your eligibility for certain products and services and to improve our products and services. We also collect certain details required by governments and regulators in Canada, including information that helps protect QWEST, the financial system and our clients from financial crime.

We gather basic information from every client and, depending on your relationship with us, we may collect additional details. When our clients have financial connections or important relationships with other people (e.g. trustee, executor, joint owner of an account, etc.), we need to know about these connections and people to help us understand how, for whom and by whom our products and services are being used and funded. We are required to collect information from these people too. If you provide us with information about another individual, we will assume that you have the authority to provide this information and have obtained their consent to its collection, use or sharing for the purposes set out in this Privacy Statement.

Cookies and Log Files

Our Website uses "cookies" and similar technologies like single-pixel GIFs and web beacons. A "cookie" is a text file that is sent to your computer or device and from your computer each time you use the site. Cookies can track how and when you use the Website and which site you visited immediately before. A cookie does not damage your system and identifies your browser, not you personally.

We use cookies to collect information such as the server your computer is logged onto, the domain name of your internet service provider, your browser type and version (for example, Netscape or Internet Explorer) and your IP address. We may also derive the general geographic area associated with an IP address.

Sometimes, we use cookies in combination with “web beacons” or similar technology to collect information about how our Website is used, such as: your IP address and location data, weblogs, time zone, date, your language preferences, browsers used, web addressees visited, other communication data, searches conducted, pages visited, and any other relevant information about your online experience.

If you are an anonymous visitor, the information in this paragraph does not personally identify you but rather numerically identifies your device, and we may share this cookie’s information with a third party marketing provider that will use it to deliver marketing about us to you while you visit other sites on the internet.

If you do not wish to receive cookies, you may be able to disable them. Although this may provide you with enhanced anonymity, it may affect the functioning of our Website.

To the extent that our Website contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.

Information about Minors

This site is intended solely for users who are not minors (13 years of age or older). We do not knowingly collect personal information about any minor, unless such personal information is provided to us through the consent of the minor’s parent(s) or guardian(s). Otherwise, under no circumstances should a minor or his or her parent or guardian submit a minor’s personal information to us through the Website, Software, Service or otherwise for any reason.

We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian as it relates to such minor, should submit such minor’s personal information to us through the Website, Software or otherwise for any reason and under any circumstances.

2.1     Using your personal information

QWEST may share your information with its employees and service providers, debt collection agencies (if we have to collect a debt), other financial institutions, financial industry regulators, law enforcement agencies, Canada Revenue Agency, and your legal representatives. Information will be shared only as needed to communicate with you, to provide the products and services requested, for the purposes described in this Privacy Statement, to operate, maintain and provide you with the features and functionality of the Website or when authorized or required by law.

With your permission, QWEST may also use your information to market QWEST products and services to you, and products and services from relevant third parties. We may send you marketing messages and materials by mail, email, telephone, text, secure messages, or through digital or social media. We may share your information with our advertisers and/or social media providers if we advertise our products and services on the Internet (including social media). For example, QWEST may ask the social media provider or social media network:

  1. to use your information to send our advertisements to you;
  2. to exclude you from receiving our advertisements; or
  3. to advertise to people who have a similar profile to you.

You may at any time refuse or withdraw your consent to our marketing by emailing cbower@qwestfunds.com.  Social media platforms also allow you to indicate your preferences to them about the advertising you receive on their platforms. Please contact your social media platforms for more information.

2.2     Disclosing your personal information

QWEST will disclose your personal information in certain circumstances such as:

  1. Providing our service providers who are responsible for processing or handing personal information with only information that is necessary to perform the services by them or by their service providers. Service providers are required by QWEST to protect personal information consistent with our privacy policies and security practices.
  2. QWEST’s service providers may be located in other jurisdictions and subject to the laws and regulations of those jurisdictions or countries, such that those countries’ governments, courts, or law enforcement agencies may access your personal information.
  3. Subject to the law, QWEST may share your information with subsidiaries and affiliates in order to manage your relationship with QWEST, detect fraud and money laundering, collect debts owed to QWEST, and market products and services that may be of interest to you.
  4. QWEST may disclose personal information related to a financial asset or liability of QWEST along with transfer of the financial asset or liability.
  5. If a client has a product or service where ownership or liability is shared with others, QWEST may share the client’s information with such other persons in connection with the product or service.
  6. Where someone is acting as a representative or we reasonably believe is acting with proper authorization, such as a legal guardian, person having power of attorney, estate representative, lawyer, accountant and, for minor children, parent or guardian, we may share information with and take instructions from them including sharing information as instructed by either representative where representatives are jointly appointed.
  7. Following death, we may also share your information with your beneficiaries or estate representatives where reasonably necessary to help in the administration of your registered plans or your estate’s financial affairs.
  8. If you are the surviving joint account-holder, we may share information about your account created or collected before a deceased joint account-holder’s death with the representative of the deceased joint account-holder.
  9. QWEST may acquire new businesses, sell some parts of its businesses, merge or amalgamate part or all of its businesses with other entities. As personal information associated with any accounts, products or services of the business being purchased/sold/merged will typically be included in such transactions, QWEST may disclose such information to such other entities as part of the transaction or review prior to the transaction. Any such disclosure will be subject to appropriate privacy and security safeguards and compliant with any applicable law.
  10. QWEST may disclose client information to meet our compliance, regulatory and financial crime risk management obligations. In such cases, we may not need your consent and will only disclose it under proper authority.
  11. We never sell client data for marketing purposes.

2.3     Retaining your personal information

QWEST will retain your personal information for as long as necessary for the identified purposes and for legal and business purposes.

2.4     Your Social Insurance Number (SIN)

QWEST is required to collect your Social Insurance Number for tax residency self-certification and for any products that earn investment income to comply with the Canada Revenue Agency’s reporting requirements.

2.5     When you connect with us online

When you access QWEST’s website, or apply for products and services online, QWEST may collect information from you, your computer, or your mobile device.

3. Accuracy and Safeguarding

QWEST is committed and will make every reasonable effort to keep your personal information accurate, complete, and up-to-date as necessary for the purpose for which it is used. However, we also rely on you to tell us when your information changes. Keeping your information accurate and current lowers your fraud risk, ensures accurate reporting on QWEST’s part and allows us to continue to offer you the highest-quality service.

We make reasonable efforts to prevent unauthorized use, sharing, loss and theft of information. We regularly audit and assess our security measures to ensure that they are effective and appropriate. Our employees who have access to your information are made aware of the importance of keeping it confidential. However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

Information may be shared with or accessed by our service providers so that they can perform services on our behalf. All service providers with access to your information must follow QWEST’s strict privacy and security standards as part of their contractual obligations. We use contracts and other measures with our service providers to maintain the confidentiality and security of your information and to prevent it from being used for any other purpose other than that for which it was intended. We do not give them client information unless we have a valid business purpose for doing so, and we have your consent or have previously informed you.

4. Accessing Your Information

You have a right to access your personal information held by QWEST. Upon request, QWEST will inform you within 30 business days of the following: a) what personal information QWEST has, b) what the information has been used for, and c) with whom the information has been shared.

If you would like access to your personal information held by QWEST, please submit a written request to the Compliance department at compliance@qwestfunds.com.

4.1 Access requests

QWEST will require you to verify your identity to ensure that the access request is legitimate. QWEST may request that you specify the type of information you would like to access. We may also ask you for additional information to confirm the scope of your request, such as the relevant time period or a specific description of the information you are seeking to access. Once we receive your written request, verify your identity and understand the scope of your request, we will provide a written response to your access request in accordance with the time frame prescribed by applicable privacy law.

If QWEST is unable to fulfill the access request within 30 business days, a written notice of a time extension will be provided within 30 business days of the request. The notice of extension will advise of the new time frame, the reason(s) for extending the time frame, and of your right to make a complaint to the Office of the Information and Privacy Commissioner for British Columbia regarding the extension.

There may be a cost to fulfilling an access request, depending on the type and amount of information requested. When there is a cost, QWEST will inform you of the estimated cost and ask you whether QWEST should proceed with the request. The information provided will be made available in a way that is accessible to you. If we have obtained information about you from others, you can ask us for the source of that information. On request and where legally permitted, we will provide you with the names of third parties to whom we have given or may have given your information. However, this will not include service providers we have used to do work for us. It will also not include reports to the Canada Revenue Agency or information that has been provided for legal and regulatory obligations.

If an access request is refused, in whole or in part, QWEST will provide written notification to the client of its refusal, reasons for refusal, and what other options are available to the client. Reasons why an access request may be denied:

  1. The personal information is unreasonably costly to provide;
  2. The disclosure of the personal information to the client would threaten the life, health, or security of another individual;
  3. The personal information cannot be disclosed without disclosing the personal information of other individuals;
  4. The personal information was generated in a formal dispute resolution process or is subject to solicitor client or litigation privilege;
  5. The personal information cannot be disclosed for legal, security, or commercial proprietary reasons, including being subject to an investigation by law enforcement; or
  6. If the information provided is inaccurate or incomplete, QWEST will amend the information as requested by the client and, where appropriate, share the amended information with relevant third parties.

5. Data Storage and Retention

The length of time that your information is retained will vary depending on the product or service and the type of information we have. Your information is retained for as long as we reasonably need it for client service, legal or reasonable business purposes and may extend beyond the end of your relationship with us. When your information is no longer required, we will securely destroy it or delete personally identifiable information. Depending on the nature of the information, your information may be stored in QWEST’s office, in various computer systems or in the record storage facilities of QWEST or our service providers.

Information may be stored and processed in any country where we have affiliates or service providers. By using our products or services, you consent to the transfer of information to countries outside of Canada — including the United States — which may provide different data protection rules. QWEST, our service providers and other third parties with whom we share information under this policy may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and be subject to the laws and regulations of those jurisdictions or countries, such that those countries’ governments, courts, or law enforcement agencies may access your personal information. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. When your information is transferred to and stored in locations outside of Canada, we will ensure it has an appropriate level of protection and that the transfer is lawful.

6. CASL Policy

We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”).  Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting and updating this Privacy Statement, we undertake various transparency initiatives to ensure we comply with CASL, which include:

  1. Consent – we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied” or specifically exempt from consent requirements. We modified or adopted our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as per CASL. When we collect your electronic contact information, you will know the exact purposes behind the collection.
  2. Content – we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
    • Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
    • Provide you with our contact information; and
    • Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
  3. Clarity – we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 8 below.

7. About this Privacy Statement

This Privacy Statement applies to the personal information of QWEST clients and prospects and individuals connected to our clients (i.e. other people on your account, and anyone who handles your financial affairs or deals with us for you). This Privacy Statement does not apply to corporate/commercial entities, but does apply to people within those organizations (including partners, directors, officers, members, shareholders and trustees).

We may modify this Privacy Statement from time to time and will post the most current version online. If we revise it, updates will take effect 30 days later.

8. Questions and Complaints

Clients should direct any questions, concerns, or complaints regarding their privacy or this Privacy Statement to the Compliance department. Our Compliance department will acknowledge, document, and investigate each privacy complaint it receives, and clients will receive a response within a reasonable time period.

Mail:    Qwest Investment Management Corp.
Compliance Department
1055 Dunsmuir Street
Suite 732, PO Box 49256
Vancouver, BC, V7X 1L2

ATTN: Chief Compliance Officer

Email:  compliance@qwestfunds.com

Clients may also contact the Office of the Information and Privacy Commissioner for British Columbia.